Justia Minnesota Supreme Court Opinion Summaries
Fairbanks v. State
After a jury trial, Appellant was found guilty of first-degree murder of a peace officer and nine other felonies. The Supreme Court affirmed Appellant’s first-degree murder conviction and all but one of his other felony convictions. Thereafter, Appellant filed a petition for postconviction relief, asserting, inter alia, that he did not actually cause the death of the officer. The postconviction court denied Appellant’s petition without an evidentiary hearing. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion when it denied Appellant’s petition without holding an evidentiary hearing. View "Fairbanks v. State" on Justia Law
Posted in:
Criminal Law
Ryan v. Potlatch Corp.
Respondent suffered a work-related back injury. Respondent and her employer entered into a “full, final, and complete” settlement of Respondent’s claims for workers’ compensation benefits related to that injury. Respondent later filed a claim petition seeking additional benefits for the back injury, alleging a lumbar spine injury with consequential depression and anxiety. The employer moved to dismiss the petition on the ground that Respondent was first required to bring a motion to vacate the existing settlement agreement before bringing a new claim. The workers’ compensation judge denied the motion, concluding that the settlement agreement did not foreclose a later claim for consequential psychological injury. The Workers’ Compensation Court of Appeals affirmed, concluding that the settlement agreement did not foreclose claims from the same incident that were not mentioned in the agreement without evidence that those claims were contemplated by the parties at the time they entered into the agreement. The Supreme Court reversed, holding that the language of the settlement agreement was sufficient settle conditions and complications that arise out of, and are a consequence of, Respondent’s workers’ compensation injury. View "Ryan v. Potlatch Corp." on Justia Law
Swaney v. State
In 2008, Appellant was convicted of three counts of first-degree murder and four counts of second-degree murder. Appellant was sentenced to life imprisonment without the possibility of release. The Supreme Court affirmed on appeal. In 2012, Appellant filed a petition for postconviction relief, alleging numerous trial errors as well as ineffective assistance of counsel. The postconviction court summarily denied most of Appellant’s claims on the ground that they were procedurally barred. Following an evidentiary hearing, the court denied Appellant’s remaining ineffective assistance of counsel claims. The Supreme Court affirmed, holding (1) most of Defendant’s claims were procedurally barred, and therefore, the postconviction court did not abuse its discretion by denying them without granting an evidentiary hearing; and (2) the district court did not err when it denied several of Appellant’s ineffective assistance of counsel claims after an evidentiary hearing. View "Swaney v. State" on Justia Law
State v. Noggle
Appellant was convicted of attempted third-degree criminal sexual conduct. The district court sentenced Appellant to eighteen months in prison and imposed a ten-year conditional release term under Minn. Stat. 609.3455(6). The court of appeals affirmed the imposition of the ten-year conditional release term. The Supreme Court reversed, holding that section 609.3455(6) does not authorize a ten-year conditional release term for the crime of attempted third-degree criminal sexual conduct, and therefore, Appellant’s ten-year conditional release term was unauthorized by law and must be vacated. Remanded with instructions to vacate Appellant’s ten-year conditional release term. View "State v. Noggle" on Justia Law
Posted in:
Criminal Law
State v. Chavez-Nelson
After a jury trial, Appellant was convicted of first-degree premeditated murder and sentenced to life imprisonment without the possibility of release. Appellant appealed, alleging several claims of error. The Supreme Court affirmed, holding (1) the district court did not deprive Appellant of his Sixth Amendment right to counsel when it denied his request for advisory counsel to assume full representation of his case at trial; (2) the district court did not commit errors that, either individually or taken together, denied Appellant a fair trial; and (3) Appellant was not prejudiced by any error in the district court’s refusal to instruct the jury on the lesser-included offense of first-degree manslaughter. View "State v. Chavez-Nelson" on Justia Law
State v. Vang
Appellant was charged with second-degree intentional murder. Appellant offered to plead guilty to that charge, but the State rejected the offer. A grand jury subsequently indicted Appellant for first-degree premeditated murder. Appellant was convicted and sentenced to life imprisonment. Appellant appealed and sought postconviction relief, claiming ineffective assistance of counsel and prosecutorial misconduct. The postconviction court denied relief. The Supreme Court affirmed, holding (1) the district court did not err in denying Appellant’s motion to dismiss the first-degree murder indictment as untimely; (2) the postconviction court did not err in dismissing Appellant’s ineffective assistance claim without an evidentiary hearing; and (3) the postconviction court’s findings that there was no prosecutorial misconduct were not clearly erroneous. View "State v. Vang" on Justia Law
State v. Washington-Davis
After a jury trial, Appellant was convicted of six counts of soliciting and promoting prostitution and conspiracy to commit sex trafficking. The district court sentenced Appellant to an aggregate sentence of 432 months’ imprisonment. The court of appeals affirmed. The Supreme Court affirmed the convictions, holding (1) the statute that criminalizes the promotion and solicitation of prostitution is not substantially overbroad under the First Amendment; (2) the district court gave plainly erroneous accomplice-liability jury instructions, but the instructions did not affect Appellant’s substantial rights; and (3) the evidence presented at trial was sufficient to support Appellant’s convictions. View "State v. Washington-Davis" on Justia Law
Nelson v. State of Minnesota
Darek Jon Nelson pleaded guilty to first-degree premeditated murder and was sentenced to life in prison without the possibility of release. The postconviction court subsequently denied Nelson's petition for postconviction relief asking to withdraw his guilty plea. In this case, the record clearly shows that Nelson understood the charges against him, understood the rights he was waiving, and understood the consequences of his plea. Therefore, the court affirmed the judgment, concluding that Nelson did not meet his burden to show that his guilty plea was not entered intelligently, accurately, or voluntarily. View "Nelson v. State of Minnesota" on Justia Law
Posted in:
Criminal Law
Kimberly-Clark Corp. Commissioner
After the Commissioner denied Kimberly-Clark's corresponding refund claims that accompanied amended corporate franchise tax returns, Kimberly-Clark appealed to the tax court. Kimberly-Clark argued that its refund claims were allowable because the Legislature’s enactment of the Multistate Tax Commission’s apportionment formula was a contractual obligation that was unconstitutionally impaired when the 1987 Legislature repealed the provisions that authorized the use of that formula. The Minnesota Tax Court concluded that the Legislature’s 1987 repeal of the apportionment formula was constitutional and therefore the Commissioner properly denied Kimberly Clark’s refund claims. Kimberly-Clark petitioned for review. The court concluded that the Legislature made no unmistakable commitment in 1983 when it enacted Multistate Tax Compact, Minn. Stat. 290.171 that was impaired when the Legislature later repealed portions of that statute. Accordingly, the court affirmed the judgment. View "Kimberly-Clark Corp. Commissioner" on Justia Law
Posted in:
Tax Law
Melillo v Heitland
Respondent filed suit against appellant for personal injuries he suffered as a result of an automobile accident. Respondent attempted to serve the summons and complaint on appellant via certified mail. The district court concluded that appellant was not properly served before the statute of limitations expired and therefore dismissed the complaint. The court of appeals reversed and remanded. The court held that service of process via certified mail does not constitute personal service under Minn. R. Civ. P. 4.03. Accordingly, the court reversed the court of appeals' decision and reinstated the district court's judgment of dismissal with prejudice. View "Melillo v Heitland" on Justia Law
Posted in:
Civil Procedure